As part of its commitment to ethics, Orano has implemented a system to receive and process disclosures (whistleblowing system). People who have access to the whistleblowing system can report without any personal interest and in good faith any behavior or incident in violation of Orano Code of Ethics or applicable laws and regulations, and which they have first-hand knowledge by having witnessed it directly or being the victim.

This system is not meant for crisis regarding an imminent danger or threat.

Our portal is hosted on a secured server at our provider Signalement.net and ensures encryption and data storage in a confidential manner.

Our portal is accessible to all members of staff (employees, interns) as well as external and occasional workers. It is also accessible to employees of our business partners (suppliers, service providers, subcontractors, and customers), as well as to job applicants.

Please note that this portal is not accessible to any whistleblower based in the United States; for any disclosure relating to an employee or an entity in the US, please use the dedicated system “Employee Concern Program”.

The group has put in place a process to ensure the utmost confidentiality, a fair processing and protection against possible retaliation, according to local applicable rules.

This procedure is detailed in the following Orano documents, accessible via the links at the bottom of this page:

• For Orano employees, in the applicable internal procedure: PO ORN CPL GEN 2-Whisteblowing System
• For external third parties, in a specific document: Whistleblowing System – Business Partners

These documents have been defined in compliance with French legislation, including the 9 December 2016 law known as “Sapin 2” and the Duty of Care law of 27 March 2017 for parent and controlling companies. The group’s subsidiaries based outside of France must determine if any adaption is required depending on their local regulations and laws.

According to French legislation, a whistleblower is:

• an individual – a legal entity, a company, an association or union cannot be a whistleblower
• who has no personal interest – this does not mean that the allegations are not related to them but that, according to French legislation, they are not financially compensated for their disclosure
• who makes the disclosure in good faith – the whistleblower must not act ill-intentioned or as retribution, by spreading false information
• who has first-hand knowledge of the situation by having witnessed it directly or being the victim – a whistleblower cannot simply report a rumor

Under these conditions, the whistleblower will benefit from the protection measures guaranteed by French law; otherwise, the person making the disclosure might face sanctions or prosecution.  

A disclosure aims at revealing or reporting information regarding:

• an offense or a crime (e.g. fiscal fraud, corruption, money-laundering, embezzlement, moral harassment, sexual harassment, discrimination…)
• a serious and obvious violation of the law, of regulations (e.g. non-compliance to health and safety rules)
• a serious and obvious violation of conventions, agreements, international accords, or commitments regularly ratified or approved by France (e.g. Europeans directives or regulations, violation of embargoes or international sanctions)
• a serious threat or prejudice to the public interest

Confidentiality and personal data

The confidentiality of disclosures is a strong legal requirement to which Orano is particularly vigilant. As such, your identity and personal data will be protected as soon as you submit your disclosure, and throughout the processing of your disclosure. The CNIL (French data protection regulator) recommends that a disclosure is not made anonymously.

In compliance with the General Data Protection Regulation 2016/679 (GDPR) applicable since 25 May 2018, whistleblowers, named individuals and any person involved in processing a disclosure has a right of access, a right of rectification and erasure, a right to object and a right to restriction. To exercise these rights, an email with any relevant attachment can be sent to Orano Data Protection Officer at DPO@orano.group.

Each disclosure is individually and confidentially processed and has its own secured interface system for sending and receiving messages. These exchanges respect the choice of the issuer if he/she preferred to remain anonymous. 

An anonymous disclosure can only be processed if the seriousness of the mentioned facts is established, the factual information is detailed and documented enough and upon the appreciation of the Referent. 

If you would simply like to ask a question, please send an email to G-ORN-compliance@orano.group.